How can an Indian exporter receive payment from a client in Russia?

Indian developers, translators, engineers and consultants do work for clients in Russia. Getting paid is harder than for a client in Singapore or Canada, because sanctions imposed by other jurisdictions affect the banks and payment systems the money passes through, while Indian foreign exchange rules treat Russia like most other countries.¹⁶⁸ This page sets out what Indian rules say, what an exporter should check, and where to find official lists. It is not legal advice; if your client, its bank or the work is in any way connected to a listed person or a restricted sector, speak to a lawyer before taking the job.

What do Indian FEMA rules say about receiving payment from a Russian client?

Indian foreign exchange rules treat a client in Russia like a client in most other countries outside the Asian Clearing Union (ACU). Regulation 3 of the Foreign Exchange Management (Manner of Receipt and Payment) Regulations, 2023 says receipts for exports to countries other than ACU members may be made in Indian rupees or any foreign currency, through an Authorised Bank or Authorised Person.¹

The FEMA (Export and Import of Goods and Services) Regulations, 2026 (the 2026 Regulations) then apply as usual:²

• Genuineness: your AD bank credits the money only after satisfying itself the transaction is genuine (regulation 4).²
• EDF: you file an Export Declaration Form (EDF) (regulation 3).²
• Realisation: you realise the full value within nine months of the invoice date, or twelve months if invoiced or settled in rupees (regulation 5, as amended).¹⁰

The difficulty with Russian clients comes from sanctions screening along the payment route.

Who do the rules on payments from Russia apply to?

Indian FEMA rules apply to the Indian exporter and its bank, RBI's screening rules apply to Indian banks, and US and EU sanctions apply to persons and banks under those jurisdictions.¹⁵⁷⁸

So a US dollar or euro payment that passes through a bank subject to US or EU rules may be stopped there, even though Indian FEMA rules would allow it.¹⁷⁸

How do you check a Russian client before taking the work?

You check a Russian client by confirming who will pay, searching sanctions lists, and asking your bank in advance. These are checks, not legal clearance:

1. Identity: get the full legal name, registration number and address of the paying entity, and its owners if possible.
2. Sanctions lists: search the client, its owners and its bank on the UN Security Council Consolidated List, OFAC's sanctions list search and the EU Sanctions Map.⁹⁸
3. The work: check whether the service could fall within a restriction in a sanctions program, for example work for a listed entity or a restricted sector. If it might, get legal advice.
4. Paying bank and route: ask which bank will send the money and in which currency, and whether it has an SRVA in India if paying in rupees.⁴
5. Your bank: tell your relationship manager in advance and ask what documents it will want: contract, invoice, client details, purpose code.
6. Who pays: if someone other than the client will pay, ask your bank first; third-party receipts need the bank to be satisfied the transaction is genuine under regulation 8.²

The checks take less time than recovering a returned payment.

Which documents and deadlines apply to payments from a Russian client?

The documents and deadlines for a Russian client are the usual export ones, plus a dated record of the sanctions searches you ran.²¹⁰

If a payment is returned, keep the bank's reason. See AML checks on international payments.

What happens if a bank holds or returns a payment from Russia?

A bank may hold or return a payment from Russia when it is stopped by sanctions screening along the route, even though Indian FEMA rules would allow it.¹⁵⁶⁸

• Indian banks: screen customers and transactions against UNSC lists under RBI's Know Your Customer Directions for commercial banks, and may ask for documents before crediting you.⁵
• United States: the Office of Foreign Assets Control (OFAC) runs several Russia-related sanctions programs, including the Russian Harmful Foreign Activities Sanctions and the Ukraine-/Russia-related Sanctions.⁶ OFAC says all US persons must comply, including US citizens and permanent residents; its FAQ also covers US-incorporated entities and their foreign branches.⁷
• European Union: the EU lists measures including the decoupling of certain Russian banks from the SWIFT messaging system and asset freezes on listed persons, binding on persons under EU jurisdiction.⁸

Keep the bank's reason for any return, and ask your bank what it needs before the client tries again.

Which RBI rules govern payments from a Russian client?

RBI's Manner of Receipt and Payment Regulations, 2023, the 2026 export regulations, the SRVA circular and the Know Your Customer Direction together govern payments from a Russian client.¹²³⁵

How does rupee settlement through a Special Rupee Vostro Account work?

A Special Rupee Vostro Account (SRVA) is a rupee account an Indian AD bank opens for a foreign bank. The client pays its own bank, which pays you in rupees from its SRVA with the Indian bank.³

• Directory: RBI does not publish country-wise lists in its circular. Its FAQs say SRVA details are in the "SRVA Directory" on the Foreign Exchange Dealers' Association of India (FEDAI) website.⁴
• Steps: ask the client which bank it uses, check the directory, and confirm with your own bank.⁴

See the Special Rupee Vostro Account guide.

Can a payment aggregator receive payment from a Russian client?

A payment aggregator may be able to, but the same issues follow the money. RBI defines a cross-border payment aggregator (PA-CB) as one that handles cross-border payments for current account transactions "that are not prohibited under FEMA".¹¹ Every PA must carry out due diligence on its merchants, check their background and monitor later transactions against the merchant's business profile.¹¹ A platform may also apply its own sanctions policy and decline a country or a client, so check the provider's published terms before you promise a client a payment route.

What are the common mistakes with payments from Russian clients?

The common mistakes are assuming FEMA approval means the payment will arrive, skipping sanctions searches, and accepting payment from an unexpected third party.¹²⁸

• FEMA as clearance: FEMA allows the receipt, but a bank under US or EU rules may still block it.¹⁷⁸
• No search record: not keeping a dated record of the sanctions searches you ran.
• Unannounced third parties: a payment from someone other than the client needs your AD bank to be satisfied under regulation 8.²
• Assuming rupee settlement: promising rupee payment before confirming the client's bank has an SRVA in India.⁴

Note: Sanctions change often and can be complex. This page explains what to check; it does not say any client or payment is permitted. For anything beyond routine work for an unlisted private client, take advice from a lawyer who handles sanctions.